Stanley Surrey (1910-1984) was arguably the most important tax scholar of his generation. Surrey was a rare combination of an academic (Berkeley and Harvard law schools, 1947-1961 and 1969-1981) and a government official (Tax Legislative Counsel, 1942-1947; Assistant Secretary for Tax Policy,...

The 2017 tax legislation brought sweeping changes to the rules for taxing individuals and business, the deductibility of state and local taxes, and the international tax regime. The complex legislation was drafted and passed through a rushed and secretive process intended to limit public comment...

With the election of Donald Trump and the Republican Party's domination of Congress, House Speaker Paul Ryan's blueprint for fundamental tax reform requires more careful analysis. The Ryan blueprint combines reduced individual rates with a destination-based cash flow type business tax applicable...

With the election of Donald Trump and the Republican Party's domination of Congress, it is time to seriously consider House Speaker Paul Ryan's blueprint for fundamental tax reform. The Ryan blueprint combines reduced individual rates with a destination-based consumption or cash flow type...

This paper aims to suggest two proposals for solving the current problems of the U.S. international tax regime that can be implemented on a bipartisan basis. To do so, the first section below will provide some context. The next section will survey recent reform proposals by both U.S....

Since the market is less subject to tax competition pressures than the location of headquarters or production facilities, reducing the PE threshold makes it easier to prevent BEPS. This has recently led some jurisdictions to enact new taxes aimed specifically at structures that seek to exploit...

The intersection of tax law and human rights can be viewed from two opposing perspectives. On the one hand, the ability of rich residents of developing countries and multinational corporations operating in those countries to evade or avoid taxation is directly linked to violations of human...

The current system of taxing the income of multinational firms in the United States is flawed across multiple dimensions. The system provides an artificial tax incentive to earn income in low-tax countries, rewards aggressive tax planning, and is not compatible with any common metrics of...